Collection of urban mobility data per urban node

The Council of European Municipalities and Regions (CEMR), representing 60 national associations of local and regional governments from 41 countries, welcomes the opportunity to comment on the draft Implementing Act on Sustainable Urban Mobility Indicators (SUMI). As the voice of Europes cities, towns and regions, CEMR works to ensure that EU legislation is realistic, proportionate and aligned with local needs.

The Free and Hanseatic City of Hamburg thanks for the possibility of participating in the indicator set. Hamburg welcomes the fact that the data provision relates only to the municipality itself and no longer to the entire interconnection area (FUA/GUA). However, the interval should be increased to 5 years. In particular, SU.2 is more likely to be collected every 5 years in German municipalities.

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Clean Cities, Europe's largest network of more than 140 civil society organisations advocating for healthy, safe and affordable urban mobility, welcomes the European Commissions initiative to collect harmonised urban mobility data per urban node.

Acknowledgement of the Process: We thank the European Commission for its transparent preparation process and constructive interaction during the development of the implementing act. We appreciate that the number of indicators initially proposed has been reduced to those considered most useful by the representatives in the working group.

ICLEI Europe welcomes the Implementing Act and appreciates the transparent process that guided its development. However, to support effective and successful implementation, we would like to offer several key recommendations: - Survey/transport model in indicator SU.2 (Number of trips per month made by persons who have their usual residence in the geographical area, broken down by the following four travel modes…

Dear Sir, Madam, Thank you for the opportunity to participate. Comments on indicator SU1: The necessary volume of traffic requires extensive data collection at many points of the transport system. The collection, evaluation and processing efforts must be kept to a minimum so that scarce financial and human resources are not absorbed by excessive analytical and documentation activities.

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The European Cyclists Federation (ECF) welcomes the European Commissions initiative to establish common urban mobility indicators for all TEN-T urban nodes and the draft implementing act. We acknowledge the draft act's pragmatic reliance on existing EU data sets to meet the 2027 deadline.

Feedback from cities clearly shows that much of the requested data is very difficult to obtain and that it is difficult to compare, e.g. in terms of modal split or fleet composition; depending on the data source or (transport) model, if one is used.

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The Transport Alliance for Clean Air, a group of companies and associations from the transport and mobility space that shares a common vision for clean air in the EU, welcomes the European Commissions commitment to collecting important indicators related to urban mobility. Data collection is indeed crucial for evidence-based policy-making and implementation.

ECTRI, the European Conference of Transport Research Institutes, welcomes the EC invitation to provide feedback on the type of urban mobility data that EU countries must collect per urban node in the fields of sustainability, safety, and accessibility. The new EC proposal under Regulation (EU) 2024/1679 is vital for collecting mobility data every four years and monitoring sustainable urban mobility from 2027.

Please find attached the contribution of German Cities Association to the public consultation on the draft Implementing Regulation for Urban Mobility Indicators under the revised TEN-T Regulation. We suggest clarification for some indicators, to postpone SU. 1 indicator on CO2 emission and to make some major changes on SU. 2 indicator on modal split.

The regional capital Düsseldorf welcomes in principle the manageable set of indicators and the Commission’s reliance on existing databases for the most part. This reduces the burden on municipalities and/or has the scope to define their own indicators in line with their actions and the local surveys that exist in any case.

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In our opinion, the entire project is positively assessed, and the implementation of the proposed regulations will enable the collection of uniform data on the mobility of residents across the European Union. Their analysis will enable the development of solutions that improve resident mobility, reduce transport exclusion, and increase the efficiency of investments and funds allocated to infrastructure maintenance…

Please find attached EIT Urban Mobilitys contribution to the public consultation on the draft Implementing Regulation for Urban Mobility Indicators under the revised TEN-T Regulation. Our feedback includes general remarks as well as specific comments on methodology, comparability, data governance, accessibility indicators and support needs for cities.

Annex list of indicators for urban mobility and data collection methods 1. 1.Indicator in the area of horizontal aspects (1) HO.1 Total number of persons, broken down by gender and age group, who have permanent residence in a given geographical area [#] In Poland, municipalities do not have access to databases containing data on permanent residence.

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Turismo de Portugal agrees with the proposal, but considers it essential to include tourism mobility in the indicators. In TEN-T urban nodes such as Lisbon, Porto and Faro, tourist flows account for a significant share of travel, including accesses between transport interfaces and visitor points.

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Poland, as a participant in the consultation on the draft implementing act and the indicators during the meetings of the Ad Hoc Working Group, appreciates that the Commissions indicator proposal reflects many aspects that are also considered important by Poland. We would therefore like to thank the Commission for the constructive cooperation throughout this process and hereby submits its final comments.

The City of Athens (municipality) is the most populous municipality within the Metropolitan Area of Attica. It does not operate an organized system for collecting macroscopic transport data for movements within its territory, as the legally responsible bodies for delivering and supervising transport services fall outside its jurisdiction.

We welcome the European Commissions efforts to harmonize urban mobility data collection across urban nodes in Member States and to contribute to the objectives of the common European mobility data space, facilitating data access, sharing, and reuse in the mobility and transport sector.

Berlin, the capital of Germany, appreciates the ongoing initiative of the European Commission and the opportunity to comment on the regulation. Berlin is particularly pleased that the data collection is now limited to the urban nodes itself and that FUA/GUA no longer play a role, which will make data collection much easier.

We welcome and support the efforts to collect the most comprehensive data on urban mobility in order to provide cities with the necessary resources to monitor their progress. However, we recommend extending the scope of data collection in subsequent years to complement the current set of indicators with additional key metrics that enable a more detailed understanding of the performance of each transport mode.

In general, the proposed indicators and their collection methods are in line with what is already available, both internally and through national portals. We believe that the indicator SA.2 Number of people seriously injured in road traffic accidents in the geographical area per year, broken down by sex, date of birth, and type of vehicle used by the person seriously injured and by other main vehicle involved in the…

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From Greece, Municipality of Larissa City, the data required for indicators such as SU3, SA1, SA2 and SA3 is not available at municipal level. The indicators are held by other national authorities (police, hospitals etc) and is not certain whether it is allowed to be provided to us. About indicator SU2, the only data we can collect, is about public transportation (train and bus).

The Department of Transport and the National Transport Authority (Ireland) are grateful for the opportunity to comment on the draft Commission Implementation Regulation which will : lay down rules for the application of Regulation (EU) 2024/1679 of the European Parliament and of the Council as regards the collection and submission to the Commission of urban mobility data per urban node in the fields of…

a.bike, Europes hub against bike theft, welcomes the Commission's initiative to establish harmonised urban mobility data collection across urban nodes. This represents a critical step toward evidence-based policymaking in sustainable urban transport.

See attached document, which is also summarized below. SALAR welcomes the Commissions transparency and considers it crucial that indicators are designed to support each urban node in achieving its own sustainable mobility objectives. The Commission should promote capacity building, methodological development, data innovation, and best practice exchange among Member States and urban nodes.

Good morning, Les wrote from the Sustainable Mobility, Traffic and Transport departments of Parla City Council: With regard to safety area indicators, these refer to ‘traffic accidents’, using the term ‘the accident’ and the hashtag ‘#accident’. However, Parla is of the opinion that this name incorporates a serious methodological failure by confusing a collision or road casualty with an unresponsible event.

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The material was submitted for comment to urban nodes in Slovakia, which expressed concerns regarding certain provisions defined in the draft implementing act. Specifically, these concerns relate to the following areas: 1. Definition of the geographical scope of individual UN and related data collection.

SU.1 Annual CO-equivalent emissions from road transport in the geographical area [t CO2 e per year]. This indicator is determined based on traffic intensity on individual roads, but data in municipalities are not available for all roads, only for the most important ones. This data cannot be monitored at the city level or individual municipalities in GUA.

When it comes to data collection, it would be preferable to have an identical methodology everywhere, or for the month if it is defined more precisely so that each entity, each country, can collect the same data. Without a clearly defined methodology, there is a risk that there are elements that are not comparable to each other.

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From Finland, the Ministry of Transport and Communications, the Finnish Transport and Communications Agency and Helsinki region as urban node have been part of the ad hoc working group preparing the Commission's indicator proposal. In its indicator proposal, the Commission has taken good account of aspects that have also been considered important for Finland.

After an assessment of the draft of the urban mobility indicators for the urban nodes, some suggestions have been made for improvement in certain aspects. With regards to the indicators in the area of Sustainability, the time frame of four years to submit data for the indicators of annual CO2 emissions and number of trips will be a challenge for the urban nodes.

The Department for Urban Development and Urban Planning of the City of Vienna makes the following comments: We welcome that most of the indicators are taken from existing data bases. The data required for SU2 can be provided from the local mobility survey.

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In connection with this consultation, the Government of the Canary Islands sets out its considerations, taking into account the impact that this legislative initiative may have on the Canary Islands, as an outermost region, considering the fact that it has unique limitations and characteristics that distinguish it from the rest of the European Union, as recognised in Article 349 of the Treaty on the Functioning of…

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COMMENTS to indicators ANNEX: General: The indicator set fails to reasonably cover freight transport and logistics; one of the two components of the upcoming SUMPs. Freiget is only addressed indirectly as a cause of problems (emission source; accident source) Re: SU.2 Number of trips per month made () Comments: - The definition assumes mobility should be locked into four modes.

These are the comments from the Swedish representatives on the proposal from the Commission. For detailed comments - see attached document. Indicators The Commission has presented a proposal for 10 indicators, divided among the three areas listed above, plus three horizontal indicators common to all areas.

The Portuguese Infrastructure IP, the entity responsible for the road and rail infrastructure in Portugal, agrees overall with the proposed indicators related to urban mobility associated with urban nodes, as well as with the method of collecting data in the areas of sustainability, safety and accessibility.

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Dear European Commission, thank you very much for the opportunity to give feedback to the proposed 13 Urban Mobility Indicators. Our feedback is the following: HO1 Population HO2 Area: OK HO3 Access nodes: -Please differentiate the nodes by number of railway stations, metro stations, tram stations and bus stations. This would allow to delete AC2.

The revised Trans-European Transport Network (TEN-T) Regulation entered into force on 18 July 2024. It requires EU countries to collect and transmit to the Commission a set of urban mobility data for each urban node in the fields of sustainability, safety and accessibility. The first transmission of data is scheduled for 31 December 2027.

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In general, it should be noted that the City of Herne, as an urban node, can only provide data in cases where such data is collected exclusively at local level (e.g. modal split surveys). From the perspective of the City of Herne, the majority of the proposed indicators are already held by national authorities (including indicators SU.3, SA.1-SA.3) and should be transmitted to the EU-Commission by these authorities…

The Flemish Region of Belgium can agree with the list of proposed indicators. However, we would like to share the following remarks regarding two indicators: SU.1 Annual CO-equivalent emissions: a project is currently ongoing to collect the data for this indicator, and it remains uncertain whether the data will be available in time for the first reporting in 2027.

Aspects considered relevant to this public consultation: Clarification of what is an urban node. This point has given rise to many doubts and discussions within AFIR. It is essential that the documents clearly explain what is meant by an urban node, how it ranks and what the justification is. Include mild injuries in definitions and indicators.

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The City of Innsbruck makes it very easier for most indicators to be identified directly by the Commission or by the Federal Government. For Urban Nodes, therefore, most indicators do not generate any additional expenditure.

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The Bavarian Ministry of Housing, Construction and Transport has serious concerns about the practicability of the implementation of the Implementing Regulation, as some of the data to be provided for the proposed indicators are not available to the Member States or the regional authorities and could only be identified with significant financial and human resources.

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The Portuguese National Strategy for Active Mobility submits this contribution on the draft Implementing Act on Urban Mobility Indicators. The Project Group for Active Mobility (GPMA) is a dedicated task force operating under the direct supervision of the Secretary of State for Mobility, within the Ministry of Infrastructure and Housing.

From the point of view of the city of Dortmund, most of the required data are usually not available at municipal level, but by national authorities. Data should therefore be provided by the Member States in particular via the competent federal authorities (e.g.

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In Île-de-France (Paris Metropolitan Area Urban Noeud), the monitoring of journeys by mode comes from the global transport survey (EGT) at annual rather than monthly intervals. This indicator (2.1) can therefore be monitored only on an annual basis.

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BIKEwise proposes developing a Danish reference LCA standard for circular micromobilitybased on validated data and scalable across the EU. The framework merges lifecycle, behavioural and health metrics to report COe per lifetime-hour and per passenger-km under the Urban Mobility Data Space.

In general, the Municipality of Loulé expresses its agreement with the proposal presented within the scope of the public consultation initiative. However, it considers it relevant that the following aspects be taken into account in the final version of the document: 1.

BIKEwise proposes that EU mobility indicators include the corporate and health dimension of sustainable transport. The BIKEwise Health Impact App links anonymised CityAnt sensor data with company mobility accounts to measure COe savings, active-mobility time and well-being value. It enables firms to replace short car trips with cycling, generating real ESG and productivity gains without using personal data.

As regards the indicator: SU.2 – Number of trips per month made by persons who have their usual residence in the geographical area, broken down by the following four travel modes: walking, cycling, individual motorised transport, and public transport believe that the ‘monthly’ characterisation of the indicator would require too many different cases of days (holiday, Saturday and public holiday, seasonality, etc.) to…

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BIKEwise proposes that the EU include behavioural-mobility indicators based on anonymised sensor data. Our CityAnt️ system collects motion and flow patterns from bicycles without any personal data, compliant with GDPR Art. 89. Such datasets reveal how people actually change travel habits, enabling evidence-based SUMPs.

For the Region of Wallonia, we will have challenges to calculate the following indicators: SU.1: the calculation is not possible at municipal level. The indicator is currently only available at regionla level. A possible workaround is to derive a value from from regional emissions and the ratio of licensed car plates per municipality and GUA. SU.2: the calculation is not possible at municipal level.

The city of Mannheim is located in Germany and is an important urban node that connects three TEN-T corridors. It is not only a major passenger hub, but with one of the largest marshalling yards and inland ports, it is also a key logistics hub. Mannheim is generally supportive of the idea of harmonised SUMI indicators.

ETSC welcomes the list of urban mobility indicators and data collection methods proposed in the draft Annex which will provide a comprehensive overview of road safety in urban nodes. Two additions to the indicators might be considered: SU2 - an additional, fifth, travel mode could be e-scooter/micromobility device. AC. 4 - could be complemented/improved by adding an indicator on the size of the bicycle fleet.

Representing the Directorate for Technical Services of the Municipality of Thermi Prefecture of Thessaloniki (Greece), please note the following: 1. Indicator SU.1: The data collection methodology should make it possible to adapt to the methodologies used on a case-by-case basis in each node so that the data are compatible. 2.

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Our contribution centres on the indicator frameworkits feasibility, methodological robustness, and comparabilityensuring results reflect real mobility conditions and inform EU policy. We support a common evaluation methodology, provided it is adaptable to diverse territorial realities and data systems.

Dear madam/sir, I would kindly suggest to update the indicator SU.2 and I would also kindly suggest to add one more indicator. I have named this indicator SU.2a and it is suggested below the modified SU.2. - the text I'm suggesting to modifiy SU.2: "SU.2 Number of trips per month made by persons who have their usual residence in the geographical area, broken down by the following five travel modes and categories…

Regarding the indicators based on railway stations as main mobility nodes (for example, "AC.4 - Number of secure bike parking facilites in the railway stations"), we see the need to add bus central stations, as they are equally important (sometimes more) in some cities. For example, in our city (Vitoria-Gasteiz) the bus station is more relevant for the transport of passengers than the train station.

Although the Municipality of Funchal acknowledges the importance of a common evaluation methodology, local context should be taken in account, as well as the availability of data. For instance, Madeira and Funchal are not covered by a railroad network, which makes it unfeasible to gather the indicators for field accessibility, namely AC1, AC2, AC3 and AC4.

Although the Municipality of Funchal acknowledges the importance of a common evaluation methodology, local context should be taken in account, as well as the availability of data. For instance, Madeira and Funchal are not covered by a railroad network, which makes it unfeasible to gather the indicators for field accessibility, namely AC1, AC2, AC3 and AC4.